Launchpad Pro — Acceptable Use and Anti-Spam Policy

EARLY DART LTD

Version 1.0 — Last updated: 13 September 2026

This policy forms part of the Launchpad Pro Terms of Service and applies to you and to every Sub-Account you operate. Breaching it is a material breach of the Agreement.

Why this policy matters to you, not just to us. Under the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) the ICO can fine the sender of unlawful marketing up to £500,000, and can fine company directors personally up to £500,000. Under the UK GDPR the ICO can fine up to £17.5 million or 4% of global annual turnover, whichever is higher. Under the Digital Markets, Competition and Consumers Act 2024, the CMA can impose penalties of up to 10% of global turnover for unfair commercial practices, including fake reviews.

You are the sender. We are the platform. The liability is yours.

Part 1 — Email marketing

1.1 The consent rule

Under regulation 22 of PECR, you must not send unsolicited electronic mail for direct marketing purposes to an individual subscriber (a consumer, and in practice also a sole trader or an unincorporated partnership in England, Wales and Northern Ireland) unless:

they have consented to receiving it; or
the “soft opt-in” applies — meaning all four of the following are true:
1. you obtained their contact details in the course of a sale or negotiations for a sale of a product or service to them;
2. the marketing relates to your own similar products or services;
3. they were given a simple means of refusing at the point their details were collected; and
4. they are given a simple means of refusing in every message.

1.2 What counts as valid consent

Consent must meet the UK GDPR standard: freely given, specific, informed and unambiguous, given by a clear affirmative action.

Valid:

An unticked checkbox the person actively ticks
A clear statement of who will contact them, how, and about what
Separate consent for email, SMS and telephone if you want all three
Consent naming you specifically, and naming any third party who will also market to them

Not valid:

Pre-ticked boxes
Consent bundled into terms and conditions acceptance
Consent as a condition of access where marketing is unrelated to the service
Silence or inactivity
Consent obtained by a third party where you were not specifically named
“Indirect” or bought-in consent where the buyer is not named
Consent that is more than a reasonable period old — the ICO’s guidance suggests reviewing consent every two years, and older consent is increasingly hard to defend

1.3 Purchased and rented lists

You must not upload a purchased, rented, scraped or harvested email list to Launchpad Pro.

If you intend to rely on a third-party list, you must be able to show that the individuals gave consent naming you specifically, and you must retain evidence of that consent including the source, the date, the wording shown, and what the person was told. In practice almost no commercially available list meets this standard. The ICO has issued multiple enforcement notices against organisations relying on bought-in consent.

1.4 Business-to-business email

Emails to corporate subscribers — a registered company, a limited liability partnership, a Scottish partnership, or a government body — are not caught by regulation 22 of PECR.

But the UK GDPR still applies. A named individual at a company (steve@company.co.uk) is personal data. You still need:

a lawful basis under Article 6 — usually legitimate interests, supported by a documented Legitimate Interests Assessment;
to provide privacy information under Articles 13/14, including where you got their details from;
to honour the right to object to direct marketing, which is absolute; and
to identify yourself and provide an opt-out in every message.

Generic addresses (info@, sales@, enquiries@) are usually not personal data, but treat them cautiously.

1.5 Every marketing email must

Clearly identify you as the sender, including your registered company name, company number and registered office address (Companies Act 2006 and the Electronic Commerce (EC Directive) Regulations 2002)
Not disguise or conceal the sender’s identity
Not use a false or misleading “from” name, reply-to address, or subject line
Include a valid, working, free and simple unsubscribe mechanism in every message
Use a valid reply address that is monitored
Where you white-label, identify your business — not ours, and not our infrastructure provider’s

1.6 Unsubscribes

You must action an unsubscribe request promptly — the ICO expects this within 28 days at the absolute maximum, and in practice you should aim for immediate or within 24 hours
Unsubscribing must not require the person to log in, create an account, confirm by reply, or give a reason
You must maintain a suppression list and never remove anyone from it
Suppression lists must be retained indefinitely — this is one of the few cases where indefinite retention is the compliant answer, because you need it to honour the opt-out

1.7 Deliverability thresholds

We monitor sending reputation across the Platform. You must maintain:

Metric	Threshold
Hard bounce rate	Below 3%
Spam complaint rate	Below 0.1% (1 in 1,000)
Unsubscribe rate	Below 1% consistently

Exceeding these damages deliverability for every user on shared infrastructure. If you exceed them we may throttle, pause or suspend your sending, and we will contact you to agree a remediation plan. Repeated or wilful breach may result in termination.

You must:

Remove hard bounces immediately
Remove soft bounces after repeated failures
Validate your list before any large send
Warm up new sending domains gradually
Configure SPF, DKIM and DMARC on your sending domain
Not send to addresses that have not engaged for an extended period without re-permissioning

Part 2 — SMS and MMS marketing

2.1 Consent

Marketing SMS to an individual subscriber requires consent or the soft opt-in, on the same basis as email under regulation 22 of PECR. Consent for SMS must be separate from consent for email — a single “yes please contact me” tick does not cover both unless the wording made that clear.

2.2 Every marketing SMS must

Identify you as the sender, in the message body or via a registered alphanumeric sender ID
Include a free and simple opt-out, normally “Reply STOP to opt out”
Not use a sender ID that impersonates another organisation, a bank, a delivery company, or a government body

2.3 STOP handling

You must process STOP, UNSUBSCRIBE, END, CANCEL, QUIT and OPTOUT keywords
Opt-outs must take effect immediately
You must never message a number that has opted out
The Platform handles standard keyword opt-outs automatically, but you remain responsible for ensuring opt-outs are honoured across every channel and list

2.4 Sender IDs and number rules

Alphanumeric sender IDs must be registered with the relevant aggregator and must accurately represent your business
You must comply with the Mobile Ecosystem Forum (MEF) Code of Practice and the rules of the UK mobile network operators
You must not spoof, mask or rotate sender IDs to evade filtering
“Snowshoeing” — spreading sending across many numbers or sender IDs to avoid volume-based filtering — is prohibited

2.5 Timing

Do not send marketing SMS outside reasonable hours. As a rule, send between 08:00 and 20:00 in the recipient’s local time, and not on public holidays unless the recipient would clearly expect it.

Part 3 — Telephone marketing

3.1 Live calls

Under regulation 21 of PECR you must not make unsolicited marketing calls to a number that:

is registered with the Telephone Preference Service (TPS) or the Corporate Telephone Preference Service (CTPS); or
has told you they do not want to receive your calls.

You must screen your calling lists against the TPS and CTPS. Screening must be recent — the ICO expects screening at least every 28 days, and more often for large campaigns. Keep evidence of screening.

The TPS exception applies only where the subscriber has given you specific consent to call them despite their TPS registration.

3.2 Sectors requiring consent regardless of TPS

Certain calls require prior consent and cannot rely on the absence of a TPS registration:

Claims management services — regulation 21A PECR
Pension schemes — regulation 21B PECR

Calls about these without consent are unlawful even to numbers not on the TPS.

3.3 Automated and recorded message calls

Under regulation 19 of PECR, calls made using an automated calling system that plays a recorded message require prior specific consent from the recipient. TPS registration is irrelevant — you need consent either way. This is one of the most heavily enforced areas of PECR.

3.4 Ofcom rules

You must comply with Ofcom’s statement on persistent misuse of networks, including:

Abandoned call rate must not exceed 3% of live calls in any 24-hour period per campaign
An abandoned call message must be played within 2 seconds of the call being answered, identifying you, explaining the call was for marketing, and giving a free opt-out number
No repeat calls to a number that produced an abandoned call within 24 hours, unless with a live agent
Answer machine detection false positive rate must be kept below 3%, and you must keep records
A valid, non-premium-rate CLI must be presented on every outbound call, and it must be a number the recipient can call back

3.5 Call recording

If you record calls, you must:

Tell people at the start of the call that the call is being recorded, and why
Have a lawful basis under Article 6 UK GDPR
Handle recordings as personal data, with defined retention and access controls
Not record where the caller objects, unless you have an overriding basis
Remember that recording a call without informing all parties may engage the Investigatory Powers Act 2016 and the Regulation of Investigatory Powers Act 2000 in a business context

Part 4 — Content and conduct standards

4.1 Advertising standards

All marketing sent through the Platform must comply with the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the CAP Code). In particular, it must be:

Legal, decent, honest and truthful
Capable of substantiation — you must hold evidence for every objective claim before you make it
Not misleading by action or omission, including through pricing presentation
Clearly identifiable as marketing
Socially responsible

Claims such as “guaranteed results”, “risk-free”, “No. 1”, “fastest” or specific income figures require robust documentary evidence.

4.2 Pricing and consumer protection

Under the Digital Markets, Competition and Consumers Act 2024 you must not:

Drip price — display a headline price and add unavoidable mandatory fees later. Mandatory charges must be included in the headline price or clearly stated up front
Use fake or incentivised reviews without clear disclosure, or conceal that a review is incentivised
Use fake urgency or scarcity — countdown timers that reset, “only 2 left” claims that are untrue, “sale ends today” that never ends
Use subscription traps — making cancellation difficult, or failing to give clear renewal reminders
Falsely claim endorsement, approval or authorisation

4.3 Prohibited sectors without authorisation

You must not use the Platform to market the following without holding the relevant UK authorisation and without our prior written agreement:

Sector	Required authorisation
Consumer credit, loans, debt advice, debt management	FCA authorisation
Claims management	FCA authorisation
Investments, insurance, mortgages, pensions	FCA authorisation
Cryptoassets	Compliance with the FCA financial promotion regime
Gambling, betting, lotteries	Gambling Commission licence
Medicines, medical devices, health claims	MHRA compliance; CAP Code health claims rules
Food and nutrition health claims	GB Nutrition and Health Claims Register
Alcohol	CAP Code alcohol rules
Legal services	SRA, CILEx or equivalent, where reserved activities are involved
Energy performance, green claims	CMA Green Claims Code

4.4 Political communications

Any political or campaign material must comply with the Political Parties, Elections and Referendums Act 2000, the Representation of the People Act 1983, and the digital imprint regime under the Elections Act 2022, which requires most paid and organic political campaigning material to carry an imprint identifying the promoter.

4.5 Absolutely prohibited

You must never use the Platform for:

Child sexual abuse material. We report all such material to the National Crime Agency and the Internet Watch Foundation, preserve evidence, and terminate immediately without notice or refund
Terrorist content or content glorifying terrorism
Content that incites hatred or violence, including content that would be an offence under the Public Order Act 1986 or the Online Safety Act 2023
Phishing, smishing, vishing, or any attempt to obtain credentials or financial details by deception
Malware, ransomware or malicious code distribution
Fraud, including advance fee fraud, romance fraud, investment fraud and impersonation of banks, HMRC, DVLA, delivery companies or government bodies
Pyramid schemes, Ponzi schemes, and business models banned under Part 3 of the Trading Schemes Act 1996
Sale of illegal goods, counterfeit goods, or controlled drugs
Harassment, stalking, doxxing or coordinated abuse
Sexually explicit material

Part 5 — Sub-Accounts and your clients

Where you provide Sub-Accounts to clients:

You are responsible for their conduct. Their breach is your breach
You must pass these obligations on to them in your own terms, at a standard at least as protective as this policy
You must have a written agreement with each client covering acceptable use, data protection and marketing compliance
You must monitor their usage and act on complaints
You must be able to suspend a Sub-Account promptly if we ask you to, and you must comply with any such request without delay
You must give each client privacy information consistent with your own privacy policy

Part 6 — Enforcement

6.1 Monitoring

We monitor Platform usage for spam signals, complaint rates, bounce rates, sending patterns and content indicators. We may inspect content where we have a reasonable basis to suspect a breach.

6.2 What we may do

Depending on the severity, and acting proportionately, we may:

Contact you to discuss the issue and agree a remediation plan
Throttle or pause sending on your Account or a Sub-Account
Suspend the relevant feature or the Account
Terminate the Account
Report to the ICO, Ofcom, the police, the NCA or another authority where required or appropriate

For breaches capable of remedy, we will normally give you notice and a reasonable opportunity to fix the problem before suspending. We will act immediately and without notice where there is a serious and immediate risk of harm, illegality, fraud, or damage to the Platform’s shared sending reputation.

6.3 No refund for termination for cause

Where we terminate for breach of this policy, no refund is due for the unused portion of the subscription period, except where the law requires one.

6.4 Costs

Where your breach causes us loss — including blacklisting of shared IP ranges, aggregator penalties, carrier fines, regulatory investigation costs or third-party claims — you will indemnify us under clause 9 of the Terms of Service.

6.5 Reporting abuse

To report abuse of the Platform, email contact@earlydart.com. We investigate every credible report.

Part 7 — Your compliance checklist

Before running any campaign through Launchpad Pro:

I have a lawful basis under Article 6 UK GDPR for this processing, and I have documented it
I have valid consent, or the soft opt-in genuinely applies, for every recipient
I hold evidence of consent: source, date, wording shown, and what was said
I have screened against the TPS and CTPS if I am calling, within the last 28 days
My list contains no purchased, rented, scraped or harvested contacts
Every message identifies my business, company number and registered address
Every message contains a free, simple, working opt-out
My suppression list is applied and up to date
Every objective claim in my copy can be substantiated with evidence I hold now
My pricing includes all mandatory charges in the headline figure
Any urgency or scarcity claim is genuinely true
I have a published privacy policy covering this processing
I am registered with the ICO and my fee is paid
I am authorised by the relevant regulator if I operate in a restricted sector
I have told recipients if they will be interacting with an AI chatbot or voice agent

EARLY DART LTD, registered in England and Wales, company number 16156441. This policy is not legal advice. If you are unsure whether your marketing is lawful, take advice before you send it.